What is a fractional head of tax? A guide for family offices and founder-led groups

A fractional head of tax is a senior tax adviser who takes on the head of tax role for your family office or company for an agreed share of their time, usually under an annual retainer. They own the overall tax position, coordinate your other advisers and take the senior decisions, and you don’t have to hire a full-time executive. The model suits families and founder-led groups whose tax affairs are complex enough to need senior judgement every month, but not enough to fill a senior person’s week.

In the UAE the question has become more pressing since federal corporate tax took effect for tax periods (usually the financial year) starting on or after 1 June 2023. Holding companies, family offices and free zone entities that never filed a tax return now have registration, returns, transfer pricing and record-keeping to manage, on top of the cross-border questions that wealthy families have always faced.

What does a fractional head of tax actually do?

The role is the same as an in-house head of tax, and the difference is the time commitment and how it’s paid for. In practice the work falls into five areas.

Owning the overall position

Someone has to hold the full picture: which entities exist, where each is resident, which returns are due, which positions have been taken and why. In most family offices nobody holds that picture, and each adviser sees the part they were asked about.

Coordinating advisers across countries

A family with interests in the UAE, the UK and Europe will usually have a lawyer, an accountant and a tax adviser in each place. A head of tax makes sure their advice fits together, so that a restructuring recommended in one country doesn’t create a charge in another.

Early sight of decisions

Acquisitions, disposals, relocations and new structures are cheapest to get right before they’re signed. A head of tax who sits close to the family or the CFO sees them early enough to shape them.

Oversight of compliance

Reviewing returns and the positions behind them before they are filed, checking that registrations and deadlines are met, and making sure the evidence for each position exists.

Dealing with tax authorities

Handling routine questions from the Federal Tax Authority (FTA) and other authorities, and knowing when a question is turning into a dispute that needs specialist support.

A fractional head of tax also reviews advice the family receives elsewhere. In our experience, more of that advice now starts as an answer from an AI tool. That can be a useful first draft, but it carries no professional responsibility for the result.

How is it different from using an accounting firm or a tax adviser?

A traditional adviser answers the question they are given, based on the information they are shown, but a head of tax decides which questions need asking. They have access to the family’s or group’s information, attend the meetings where decisions are made, and take responsibility for the tax function as a whole.

That doesn’t replace your existing firms: your accountants still prepare accounts and returns, and your lawyers still draft documents. The head of tax sits between them and the family, sets priorities and checks the result.

How is it different from an interim head of tax?

An interim head of tax is usually full-time for a fixed period, for example while a permanent hire is found or during a transaction. A fractional head of tax is part-time and ongoing. Brewer Morris, a recruiter of senior tax people, describes the same distinction: interim covers a gap, and fractional is a standing arrangement for organisations that need senior oversight but not a full-time role (Brewer Morris, October 2025).

Who typically uses a fractional head of tax?

Three groups use the model most.

Family offices are the first, and in our experience most single family offices do not employ a head of tax. They instruct several firms across several countries, and nobody sees the whole position. Our guide to when a family office needs a head of tax sets out the usual triggers.

Founder-led groups are the second. A business that has grown into several countries often has tax obligations in each, a finance team that files returns, and nobody senior who owns the risk.

Companies with a junior tax team are the third. Where a tax manager exists but has no one senior to escalate to, a fractional head of tax reviews the work and takes the decisions above the manager’s level.

What does a fractional head of tax cost compared with a full-time hire?

A full-time head of tax in Dubai is a senior executive hire. One 2025 recruiter salary guide put monthly salaries for a senior tax manager or head of tax at AED 40,000 to AED 60,000 or more (Alchemy Search, 2025). Those are 2025 figures, and an employer also pays for health insurance, end-of-service gratuity and usually a bonus. A fractional arrangement costs a fixed annual fee set for the scope and access you need. We compare the two in detail in fractional head of tax vs a full-time hire.

The more useful comparison is often with the status quo: many families already pay several firms for tax advice each year. A head of tax doesn’t necessarily add to that bill, because their job includes deciding which advice is needed and from whom.

What does a fractional head of tax cover in the UAE?

For a UAE-based family office or group, the agenda usually includes:

• corporate tax registration, returns and the choice of tax period for each entity, as set out in our UAE corporate tax guide for family offices and holding companies;
• whether free zone entities meet the Qualifying Free Zone Person conditions for the 0% rate;
• the treatment of foundations and trusts under Article 17 of the Corporate Tax Law;
• tax residency for family members who have moved to the UAE, and tax residency certificates;
• substance and place of management for UAE and foreign companies;
• CRS, FATCA and CARF reporting that affects the family’s accounts and entities;
• related-party pricing between the family office, the family and operating companies.

The international side needs as much attention as the UAE side. Moving to Dubai rarely ends a family’s exposure to tax elsewhere, whether through former residence, assets, trusts or family members who stay behind.

How does an engagement usually start?

Most engagements begin with a review of the current position: the entities, the countries, the advisers involved and the decisions coming up. That review produces a list of issues and an action plan, with an owner for each action. From there the head of tax works to an agreed reporting schedule with the family, the board or the CFO.

A written mandate should set out the countries and entities covered, the access you have, the response expectations, and what falls outside the retainer.

How Within works

Within, by PBF, is fractional tax advisory: your tax team, within your business. It is a senior team rather than one person, working as part of your family office or business alongside your accountants, lawyers and trustees, and covering ongoing tax advice and compliance as well as questions on investments, entry and exit. PBF is an independent international tax practice based in Dubai. Your mandate sets out the work included, and in the first 90 days we map your tax agenda, agree an action plan and set a reporting schedule. See how Within works.